Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The respondent determined deficiencies in the petitioners' income tax as follows:
Taxable Docket Year No. Petitioners Ended Deficiency 5841-66 Stephen Z. Coary... 12/31/63 $312.87 4467-66 Stephen Z. Coary & Marlene Coary... 12/31/64 $414.24
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